Union Presses Ahead with Greening Change Demands

Farm visit offer to Cabinet Secretary

NFU Scotland is pressing Scottish Government to strip out gold-plating from within Scotland’s greening rules and remove the competitive disadvantage faced by our growers.

While the Brexit vote will inevitably lead to different arrangements for Scottish agriculture in the future, the Union is pressing ahead with proposed changes to greening on the expectation that existing arrangements for direct support through the CAP will remain in place for future scheme years.

The Union believes that there is much that can be done to simplify and improve the current implementation of greening in Scotland notwithstanding European Commissioner Phil Hogan’s imminent proposals at a European level for simplification.

Areas where gold-plating can be stripped out of Scottish rules include the growing of Nitrogen Fixing Crops (NFC) to meet greening requirements; the use of conversion factors when calculating Ecological Focus Areas (EFA); grazing on buffer strips; management of fallow land and a greater choice of EFA options including forestry and hedges.

The Union has invited Scotland’s Cabinet Secretary for the Rural Economy, Fergus Ewing to visit an arable farm in the weeks ahead to see how Scotland’s existing greening measures are impacting on farm and hear how growers in other parts of the UK are operating to a preferential set of greening rules.

In writing to the Cabinet Secretary, President Allan Bowie said: “Last week’s decision for the UK to leave Europe means that future delivery of support at a Scottish or UK level must be discussed and agreed and the Union’s job will be securing the best deal possible for our farmers and crofters from that negotiation.

“However, until we are officially out of Europe and no longer benefitting from the CAP, we must continue to operate as before – and that means seeking significant changes to our greening requirements to remove the gold-plating introduced at a Scottish level.

“On using Nitrogen Fixing Crops to meet EFA requirements, Scotland-only management rules on harvesting and field margins around put Scottish growers at a competitive disadvantage with respect to growers in England. For 2016, a third management prescription was added for Scotland, requiring farmers growing NFC as an EFA option to grow at least two such crops.  The area of the largest crop must not account for 75% or more of the NFC EFA crop area.  

“For many growers, this makes this option impractical and on farms with a relatively small EFA obligation, the smaller of the crops would be too small to be economically produced, stored, transported and marketed.  

“EFA conversion factors were included by Europe as an option to simplify the burden of measuring EFA land on both farmers and officials.  Unlike the rest of the British Isles and Eire, the Scottish Government decided not to take advantage of this simplification.  As a result, in Scotland, it means ridiculous hoops are required to record the actual width of Buffer Strips and Field Margins measured along their entire length, and inspected to those measurements. This is a nonsense for Scotland where watercourses or field boundaries are rarely in a straight line.

“As Buffer Strips and Field Margins are particularly helpful in helping to produce wildlife corridors we believe that the use of the Conversion Factors would encourage uptake and so be environmentally beneficial, as well as simplifying administration.

“EU provides the option to allow EFA Buffer Strips to be grazed.  The same is not permitted for Field Margins.  The Scottish Government did not take advantage of the grazing option, stating that it wanted to avoid confusion amongst farmers.  

“Unfortunately, not allowing grazing is a serious disincentive to the establishment of Buffer Strips by farmers needing to graze livestock on fields that have a water course on their boundary.  

“On management of EFA fallow, Scotland believes it is in accordance with guidance from Brussels.  However, in England, farmers are allowed to use mechanical methods to control weeds and conduct drainage work during the Fallow period. In 2015, many Scottish farmers suffered significant weed problems that could not be addressed by the spot treatment permitted here, those weed problems spread, and the result has been an increased need for more spraying. We believe mechanical weed control is permitted within EU requirements.

“Last winter many Scottish farms also experienced flooding and damage to drains.  The logical time to undertake maintenance work is when land is out of crop.  Scottish growers are precluded from doing drainage works during the fallow period by the current interpretation of the rules in Scotland. That, again, isn’t the case in England.

“Scotland also needs a broader range of EFA options and Europe has indicated it will accept changes to Scotland’s current list.  That opens the door to further options, which have real environmental benefit, being made available from 2017.  In particular, we believe that hedges and forestry should be added.

“These examples of gold-plating also need to be viewed alongside the complete nonsense introduced in Scotland this year, requiring nutrient management plans on permanent grassland.  That is something we will be writing to the Cabinet Secretary about in due course.

“Given the uncertainty that lies ahead, Scotland’s growers deserve to get the best deal from greening measures and Scottish Government use this opportunity to strip out its own gold-plating.  That would make the years ahead where we continue to operate within the CAP more manageable and efficient for our farmers while still delivering meaningful environmental benefits.”  


Contact Bob Carruth on 0131 472 4006

Date Published:

News Article No.: 151/16

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